IRCCourt RulingsMay 2, 1978
…yers and employees under qualified corporate retirement plans. H. Rept. 378, 87th Cong., 1st Sess. (1961), 1962-3 C.B. 261; S. Rept. 992, 87th Cong., 1st Sess. (1961), 1962-3 C.B. 303. However, the statute provided that for a plan covering a self-employed individual to qualify, it had to meet certain additional require…
IRCCourt RulingsMay 9, 1988related by meaning
e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted.
An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
IRCCourt RulingsSep 17, 2026related by meaning
n effect at all relevant times, regulation references are
to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure.
Served 09/17/26
2
[* 2 ] there were no changes in the IRS approach to the issue after review
of…
IRCCourt RulingsSep 3, 1998related by meaning
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
IRCCourt RulingsFeb 12, 2008related by meaning
oner ,
T .C . Memo . 2004-125 .
- 6 -
Petitioner has not argued, and she has failed to
demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right .
Consequently, we must uphold TRHCA section 408 if it bears a
rational relationship to a legitimate govern…
IRCCourt RulingsMay 23, 2005related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2001,
the taxable year in issue. All monetary amounts are rounded to
the nearest dollar.
T.C. Summary Opinion 2005-62
UNITED STATES TAX COURT
THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v
.
COMMISS…
IRCCourt RulingsJan 25, 1968
…co-Del. We attach little significance to the fact that Philco-Del did not contribute to the plan in 1961 and that in 1963 Ford established its standard stock-purchase plan for the Philco-Del employees. Under the terms of the plan, the Philco board of directors had the unfettered discretion to make any or no contributio…
T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer … IRCTreasury DecisionsMay 23, 2016related by meaning
ple, Deputy Commissioner for Services and Enforcement.
Approved: April 29, 2016.
Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy).
Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011)
[1] Section 20…
IRCCourt RulingsApr 26, 2005related by meaning
…ns and to fashion equitable
remedies tö resolve these controversies." Simmons v.
Commissioner, T.C. Memo. 1995-422; see also Stevens v. Commissioner, T.C. Memo. 1985-192; Wenzel v. Commissioner, T.C.
Memo. 1982-595, affd. 707 F.2d 694 (2d Cir. 1983). Rather, in a
declaratory judgment action under section 7476, we must …
IRCCourt RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsDec 9, 1971related by meaning
n will be entered under Rule 50.
Drennen, /., dissents.
All statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. In addition to the $7.4 million per year, $1.2 million was to be contributed by the employers over a 3-year period to pay benefits which had vested under the 196.1 agree…
91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction IRCFinal Rules (FR)Aug 28, 2026related by meaning
on, Publications and Regulations, Associate Chief Counsel, (Procedure and Administration) Department of the Treasury.
In concurrence:
Kurt D. Dykstra, General Counsel, Office of Personnel Management.
[FR Doc. 2026-17622 Filed 8-27-26; 8:45 am]
BILLING CODE 6325-63-P; 4831-GV-P; 4510-29-P; 4169-69-P
IRCCourt RulingsJul 9, 1997related by meaning
…n all
respects relevant for this case, to the proposed regulations.
See Hall v. Commissioner
, T.C. Memo. 1991-133. In general
temporary regulations remain in effect until replaced by final
regulations or withdrawn. Id.
The temporary regulations in this
case have been neither replaced nor withdrawn, so we rely on
them.…
IRCCourt RulingsMay 15, 1978related by meaning
…ards provisions of ERISA. 29 Fed. Reg. 56462 (1976).
Ets-Hokin & Galvan, Inc. v. Commissioner, T.C. Memo. 1962-136.
The term “period of severance” is defined under sec. 2530.200b-9(a)(3)(v) as follows:
IRCCourt RulingsSep 11, 1972
…d secs. 1.72 — 1(e)(2) and 1.72-8(a) (1), Income Tax Regs.
H. Rept. No. 378, 87th Cong., 1st Sess. (1961), 1962-3 C.B. 261, 290, and S. Rept. No. 992, S7th Cong., 1st Sess. (1961), 1962-3 C.B. 303, 346, both state in this respect:
(3) Life insurance contracts. — Paragraph (3) of the new subsection (m) is applicable to …